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Reissued MRP: How is it the same and
how is it differentKristin KerrEOA, Inc.
Construction Inspection WorkshopJanuary 2016
Outline of Presentation Regulatory Background
New Municipal Regional Permit
State Construction General Permit
Resources
Terms MRP = San Francisco Bay Municipal Regional
Permit NPDES = National Pollutant Discharge Elimination
System Receiving Water = Waters of the U.S. or creeks,
rivers, lakes or bays MS4s = Municipal Separate Storm Sewer Systems RWB = Regional Water Board
Terms BMPs = Best Management Practices
CASQA Definition: Includes schedules of activities, prohibitions of practices, maintenance procedures, and other management practices to prevent, eliminate, or reduce the pollution of waters of the receiving waters. BMPs also include treatment requirements, operating procedures, and practices to control plant site runoff spillage or leaks, sludge or waste disposal, or drainage from raw material storage.
Stormwater Regulations
U.S. EPAU.S. EPA
State Water Resource Control Board
State Water Resource Control Board
Regional Water Quality Control Board
9 regions
Regional Water Quality Control Board
9 regions
Municipal Separate Storm Sewer System
(MS4)
Municipal Separate Storm Sewer System
(MS4)
Clean Water Act establishes NPDES permit program
NPDES Permitting authority in CA
Issues MRP to Phase I MS4s
Implement Stormwater Program
Construction Site RegulationsState Board/
Regional Board
SW Construction General PermitMunicipal Regional Permit
Construction Sites disturb ≥1 acre
City/County Construction Site Control Program
Construction Sites disturb <1 acre
Municipal Regional Permit (MRP)
Applies to 76 cities, counties, and districts in:• Santa Clara, Alameda,
Contra Costa, and San Mateo Counties
• Fairfield and Suisun City (Solano County)
• Vallejo (Solano County)
Regional permit regulating municipal stormwatersystems
Municipal Regional Permit (MRP)
First adopted by Regional Water Board: October 14, 2009
Permit renewed every 5 years
Reissued November 19, 2015
Became effective January 1, 2016
Construction Site Control Program
MRP Provision C.6 Minor changes in reissued MRP Implement a construction site inspection and
control program • at all construction sites• all year long
Prevent discharges of pollutants and impacts on receiving waters
Construction Site Control Program Requirements
Legal authority – no change Plan Approval Process – no change
• Verify Plans comply with local ordinance/ requirements
• Verify sites disturbing > 1 acre filed NOI for State Construction General Permit
• Provide educational materials
Require appropriate BMPs within 6 categories –no change
Erosion Control CASQA Erosion Control BMPs
Scheduling Hydraulic Mulch Preservation of Existing VegetationHydroseeding Compost Blankets Soil Preparation/ RougheningStraw Mulch Wood Mulching Earth Dikes & Drainage SwalesSlope Drains Streambank Stabilization Velocity Dissipation DevicesSoil Binders Geotextiles & Mats Non-vegetative stabilization
Wind Erosion Control
Sediment Control CASQA Sediment Control BMPs
Silt Fence Sediment Basins Sediment TrapCheck Dam Fiber Rolls Gravel Bag BermBiofilter Bags Sandbag Barrier Street Sweeping & VacuumingTemp Silt Dike Straw Bale Barrier Storm Drain Inlet ProtectionActive Treatment Systems Compost Socks and BermsStabilized Construction Entrance/Exit Entrance/Outlet Tire WashStabilized Construction Roadway
Good Site Management CASQA Waste Management & Materials
Pollution Control BMPsMaterial Use Material Delivery and StorageStockpile Management Spill Prevention and ControlSolid Waste Management Hazardous Waste ManagementContaminated Soil Management Concrete Waste ManagementSanitary/Septic Waste Management Liquid Waste Management
Non-Stormwater Management CASQA Non-Stormwater Management BMPs
Water Conservation Practices Dewatering Operations
Paving and Grinding Operations Temporary Stream Crossing
Clear Water Diversion Illicit Connection/Discharge
Potable Water/Irrigation Vehicle and Equipment Cleaning
Vehicle and Equipment Fueling Vehicle and Equipment Maintenance
Pile Driving Operations Concrete Curing
Material & Equipment Use Concrete Finishing
Demolition Adjacent to Water Temporary Batch Plants
Other BMP Categories Run-on Controls
• Keep water from off-site, upstream property from flowing through construction site
– May bring off-site pollutants– May increase stormwater runoff flows
causing erosion or
overwhelming BMPs
Runoff Controls• Manage stormwater flow to prevent erosion or
flooding at downstream location
Other BMP Categories Active Treatment Systems
• Are there any in the area?• Adds chemicals for coagulation, flocculation and/or
filtration• State General Permit requires
– ATS Plan: O&M manual, monitoring, sampling, spill prevention plan,
– Designated operator & training– Data recording system– Numeric effluent limits for discharge
Minimum Inspection Requirements
Pre-wet season letter by September 1st Monthly inspections during wet season
• October 1st – April 30th
Applies to following sites (public & private)• disturbing > 1 acre,
• identified as “high priority”
• hillside projects disturbing > 5,000 sq ft (NEW - begin inspections July 1, 2016)
Minimum Inspection Requirements
What is a hillside site?• Based on municipality hillside development maps or
criteria
OR
• ≥ 15% slope
Certify criteria in 2016 Annual Report (due September 30, 2016)
Minimum Inspection Requirements
What is a high priority site?• Identified by municipality or Regional Water Board
• Evaluated considering following factors:– High soil erosion potential (e.g., soil type)
– Steep slope
– Proximity to creek
– Compliance issues
• RWB staff look for procedures during audit
Minimum Inspection Requirements
Complete inspection form for every required inspection
When construction ends during wet season: • Continue inspections until site fully stabilized
• If stabilizing with vegetation, assume “fully stabilized” when 70% vegetative cover
Document “Last” inspection
Inspection Recordkeeping
Tracking and reporting of data:• Site name and inspection date• Weather during inspection • Enforcement response level• Problems in 6 BMP categories or illicit discharge• Resolution of problems• Comments• (REMOVED) whether it rained since the last inspection• (REMOVED) specific problems
Inspection Recordkeeping Database/spreadsheet of inspections RWB has requested these tables Inspection tables should match Annual Report
summaries 2015-2016 Annual Reporting same as previous
years 2016-2017 Annual Report and forward
• Begin reporting hillside site inspections (NEW)
• Small reduction in reporting requirements
Enforcement Response Plan Permittees should review ERPs and confirm
meet new detailed description of contents Description of procedures/guidance for
• Appropriate enforcement actions
• Follow up inspections
• Referrals to another agency
• Time period for implementing corrective actions
• Roles and responsibilities of staff
Enforcement Response Plan Discuss escalating enforcement tools for
different field scenarios • Potential discharges
• Actual discharges
• Non-compliance with previous enforcement actions
• Sites with history of potential/actual discharges
(NEW) No longer use “violations” refers to actual and potential discharges
Enforcement Response Plan Timely Correction
• Actual non-stormwater discharges cease immediately (NEW)
– Construction General Permit authorized non-stormwaterdischarges conditionally allowed
• Corrective actions implemented– Within 10 business days,
– Or before next rain event,
– OR record rationale for longer compliance.
Source Control: Copper (Provision C.13.a)
Runoff from architectural copper can impact water quality and aquatic life• Concerns during installation,
treatment and washing
When issuing building permits require BMPs
Annually report permitting and enforcement 2016 Annual Report: report how addressed
through issuance of building permit (NEW)
Statewide Construction SW General Permit (CGP)
Applies to projects that disturb ≥1 acre of land in California
RWB staff responsible for compliance inspections & enforcement
Contains requirements for minimum BMPs, inspections, sampling, SWPPP, reporting (SMARTs), QSP/QSD certification
Why do you need to know about the CGP?
MRP requirement to • verify owners of construction sites that disturb ≥ 1
acre have filed NOI for coverage by CGP• inspect construction sites that disturb ≥ 1 acre
monthly during wet season for compliance with local ordinances
What do you need to know about the CGP?
Reviewing SWPPP, QSP inspection records, sampling results, etc. may help inform your MRP inspection
Public projects ≥ 1 acre must file for coverage under the CGP
Overall site compliance reflects on your inspection program
For More Information…
Municipal Regional Stormwater Permit http://www.waterboards.ca.gov/sanfranciscobay/water_issues/programs/stormwater/Municipal/R2-2015-0049.pdf
SCVURPPP Construction BMP Resources www.scvurppp-w2k.com/construction.shtml
SCVURPPP Training Resources http://www.scvurppp-w2k.com/workshops.shtml
CASQA Construction BMP Handbook Portal (contact your agency SW coordinator for information on how to access web subscription) www.casqa.org
